McKeel comment on Allen (6.08.12) memo 

Comment on David Allen DCAS Memo Dated June 8, 2012 

to the TBD-6000 Work Group of the ABRWH in Response 

to the SC&A Discussion Paper Update on GSI Intake Doses 

Daniel W. McKeel, Jr., M.D., GSI SEC-00105 Co-petitioner
 

June 13, 2012
 

• This brief report is a response to the Allen 6.08.12 memo in the title that replied to 

SC&A’s May 30, 2012, analysis of internal doses from radiation intakes at the General 

Steel Industries (GSI) AWE site in Granite City, IL. SC&A subsequently replied to this 

Allen DCAS report on June 12, 2012. In their second report in this series, SC&A totally 

reversed one of its major 5.30.12 findings that NIOSH had underestimated uranium 

intakes by a factor of 10-fold, i.e., by one order of magnitude. 

• In part, this is also a comment on how the co-petitioner perceives the current state of 

DCAS/NIOSH scientific process and transparency within the EEOICPA program at 

DCAS/NIOSH. There is great room for improvement. 

The two Attachment A & B letters in the DCAS
 

June 8, 2012 David Allen memo
 

1. Background: Co-petitioner McKeel questions the exact citation for these two 

letters. David Allen replied to McKeel on 6.12.12 that the reference number was 16356, 

presumably from the SRDB. He also commented that these letters were discussed at a 

2008 TBD-6000 work group meeting in which SC&A acknowledged the letters on page 

103 and McKeel participated, citing page 104 from the relevant meeting transcript. The 

implication was that, because McKeel participated, he had the relevant documents in 

his possession. That conclusion is not logical, and it is not supported by the transcript. 

Dr. Anigstein simply referred to MCW to GSI memos prior to any purchase orders. Dr. 

Anigstein said nothing about the citations, dates, titles, source, or, most importantly, that 

the two letters (Attachments A and B to Allen 6.8.12) say absolutely nothing about 

uranium. The McKeel comment that follows on pages 103 and 105 bolsters the idea 

the GSI covered period should start in 1952 because the Old Betatron facility was built 

in 1951, from GSI Board minutes Ramspott and McKeel discovered in St. Louis and 

shared with the work group. The GSI Board minutes also proved the government owned 

GSI Betatron 24 Mev x-ray machine was in place in 1952 and ready to go. This is solid, 

concrete evidence. As I understand it, DOE set the start date of the GSI covered period. 

Comments: 

(a) Allen stating that McKeel participated in a work group meeting is not 

equivalent to McKeel having the referenced documents in his possession. And it does 

not indicate the documents were provided to McKeel by OCAS/DCAS and NIOSH (see 

(b) below). 

(b) My e-mail inquiry to Mr. Allen dated 6.12.12 addressed several questions:

 [1] The Attachment A and B sources (a number is not a source). Allen 

indicating the source as “the same place as the purchase orders” is equally vague and 

not especially helpful. Because I did not get this information from Dave Allen, I 

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McKeel comment on Allen (6.08.12) memo 

researched the issue and the two letters, to be precise, are contained in FUSRAP 

document IL.28-5 on pages 17 (labeled “a-9” and on page 21, labeled a-13). The 

document is available on the DOE LM website under the GSI listing. It is interesting how 

imprecise a description of IL.28-5 that DOE provides (see below):

 [2] Does DCAS or NIOSH have any other GSI documents it has not yet 

shared with SC&A, the work group, or the petitioners? Mr. Allen did not address the 

second question in his reply to McKeel on 6.12.12. The second question was asked 

again on 6.13.12 in a follow up e-mail to Mr. Allen. 

(c) An isolated SRDB number is marginally useful to McKeel (a) because the 

source and title of the documents were not given by Allen, and (b) Long ago 

OCAS/NIOSH under former Director Larry Elliott denied McKeel direct access to SRDB 

documents or to a searchable index of SRDB documents that SC&A and DCAS have 

access to. At first, McKeel was denied knowing whether documents he sought were in 

the SRDB database, or the SRDB number/s of document/s he was seeking. After much 

negotiation, some SRDB numbers were made available to McKeel. But as in the 

present case, the number often was not accompanied by the full citation that includes 

the document source agency, the title, the year, and the pagination information, all of 

which are worldwide, standard citation notations for scientific literature. 

(d) McKeel has petitioned the Obama open.gov website to make the nonclassified portion of the DCAS SRDB open to the public. The request was never replied 

to. Whether the McKeel request was acted upon is unknown. 

(e) The lack of access to the SRDB document database puts all SEC petitioners 

at a distinct disadvantage with respect to SC&A and DCAS, as is evident from the 

present case. The policy is not claimant favorable, and it does not promote 

transparency. 

2. Site expert John Ramspott has pointed out in two e-mails the two Attachment A 

and B documents in Allen June 08, 2012, are not clearly referencing uranium purchase 

orders at all. The letters could refer to purchase orders for other metal components that 

GSI is known to have supplied to MCW. He cites Purchase Order U-83621-F dated 

6-5-62 for a “Piston Rod per MCW sketch” at a cost of $120 mentioned in IL.28-5 on 

page 30 as one example. We believe the Attachment A and B letters to Allen 6.08.12 on 

pages 17 and 21 of that document are probably irrelevant to the MCW-GSI uranium 

issue and should be hereafter disregarded because what they refer to is unclear. 

The first Ramspott e-mail was attached to my 6.13.12 reply to Mr. Allen and to 

members of the TBD-6000 work group. His second e-mail documenting the MCW piston 

rod Purchase Order is attached to this comment. 

3. It is unclear to GSI SEC-00105 co-petitioner McKeel exactly what new data or 

other information was contained in the Allen 6.08.12 memo that would lead SC&A to 

recant its view on May 30, 2012, that NIOSH had underestimated GSI intake doses by 

an order of magnitude in 2007-2008. SC&A is familiar with TBD-6000 surrogate data 

that Allen cites in support of his original calculations. What has changed or is new? 

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McKeel comment on Allen (6.08.12) memo 

4. Mr. Allen relies in his June 8, 2012, analysis on slug facility surrogate intake data 

gleaned from TBD-6000. There exists no such real (measured) intake monitoring data 

at GSI. The slug facility in TBD-6000 has not been justified as being comparable and 

similar enough to GSI to meet either Board or SC&A surrogate data criteria. The types 

and mix of uranium metal at the slug facility and at GSI were not shown to be similar, 

the source terms at both facilities could not have been similar for GSI possessed two 

24-25 Mev Betatrons and used Ra-226 and Cobalt-60 and Ir-192 as well. GSI uranium 

was exposed to photon levels that caused activation and some fission. Were similar 

sources used at the slug facility that is highlighted in TBD-6000? The use of this slug 

facility data is not based on good, solid science. Rather, it is based on convenience. 

The petitioners therefore reject this analysis outright as they have indicated for many 

years and believe the Board also should reject the slug facility uranium intake data as 

being valid for GSI, an admittedly “unique” facility by OCAS Director Elliott in 2005. 

5. Regarding the NIOSH analysis on page 2 of uranium work times. The copetitioner reiterates his objection to an analysis of uranium source term mass based 

solely on MCW purchase orders as being in any way “sufficiently accurate” for bounding 

purposes in the SEC. Purchases Orders need to be confirmed by shot logs, shipping 

manifests, receipts at either location (MCW, GSI), x-ray NDT reports, etc. None of that 

corroborative documentation exists. NIOSH cannot know (a) the MCW purchases it has 

are all that were issued, or that (b) the P.O.’s were actually fulfilled as specified. This is 

an inference on the part of science, and that is insufficient for a valid scientific 

conclusion. The Board should reject the contorted pseudo-science that NIOSH uses to 

defend its recommendation to deny SEC105, both during the covered period and in the 

residual period, based on such flimsy evidence of demonstrable sufficiently accurate 

methodology based on inferences and assumptions rather than solid representative real 

measured data. 

6. Allen on page 3, discussing the 2nd bullet, relegates the air resuspension factor 

to be a “TBD” issue based on the peculiar unsound reasoning that because the value is 

contentious among work groups, then the issue should be deleted as an SEC issue. It 

and the use of TIB-70, are crucial residual period SEC issues at many sites. SC&A 

believes the value NIOSH uses for resuspension rate is a 100% underestimate. The 

TBD-6000 work group has allowed too many acknowledged SEC/Appendix BB overlap 

issues and findings to be put on the back burner as Appendix BB issues, and thus 

kicked down the road until after the June 20 presentation of GSI SEC-00105 to the full 

Board in New Mexico. This approach is very unfair and adversarial to GSI claimant 

interests. 

7. The co-petitioner disagrees with NIOSH about the 3rd bullet; that there is no 

worker exposure to uranium intakes in the shooting room. During the covered period 

and thereafter dust was several inches deep in the shooting room. Uranium Ingot and 

dingot surfaces were abraded by chains and crane movements and undoubtedly 

deposited on the floor and many surfaces. No recorded uranium surveys of the Betatron 

buildings at GSI from 1952 to 1988 have survived. ORNL found little uranium in 1989 in 

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McKeel comment on Allen (6.08.12) memo 

the Old Betatron building only, 23 years after the covered AEC uranium contract 

period ended at GSI, because the facility had been cleaned up with vacuums, and had 

been power washed. The conditions at GSI in 1989 bear no direct relation to residual 

uranium load during the late 1960s, 1970s and early 1980s. These levels of surficial 

uranium loading are unknown and unknowable. The values NIOSH uses, and SC&A 

accepts, for the residual period are meaningless is any real scientific or practical sense. 

The data NIOSH uses in their calculations are inappropriate, and the work group and 

full Board should reject the analysis, because it is based on too little real data, if they 

want to claim that “good science” is practiced in this compensation program. 

8. 5th Bullet, page 3. In a truly bizarre contortion of logic, Allen and NIOSH in the 

June 8, 2012 memo admit the consensus average work week number of 3250 hours at 

GSI, that had been agreed to in October 2007 in Collinsville IL, should be used, but they 

refuse to use it now in the SEC bounding calculations until “the next revision of the 

TBD,” date unannounced. The “next” revision of Appendix BB will be the first revision as 

Rev. 0 was issued in June 2007 and NIOSH has steadfastly refused to revise it. The 

TBD-6000 work group is not finished with resolving Appendix BB issues, and no 

meeting is scheduled to do this. Claimants deserve better treatment. 

Respectfully submitted, 

Daniel W. McKeel, Jr., M.D. 

GSI SEC-00105 co-petitioner 

Phone: (573) 323-8897 

Fax: (573) 323-0043 

US mail: P.O. Box 15, Van Buren, MO 63965 

E-mail: danmckeel2@aol.com 

Enclosure: MCW P.O. U-83621-F and Ramspott 6.12.12 e-mail regarding it 

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aolrich://34050941040/ 

Subj: The Piston PO is on Page 30 (see below) 

Date: Tuesday, June 12, 2012 7:39:34 PM 

From: jwramspott@sbcglobal.net 

To: danmckeel2@aol.com 

Ramspott:

That $48 dollar payment that is referenced Dave Allen and SC&A may easily be for some "odd ball" Special job not even

pertaining to Uranium and The Betatron . See the prime example of this in another AEC/ Mallinckrodt 

Purchase Order BELOW: 

So using the "Two letters (Attachment A and Attachment B)" for a "guide / example etc." for any kind of

AEC Uranium Project analysis / hours etc. is not "provable or valid". This AEC/Mallinckrodt PO EXAMPLE below, was for 

$120 for a "Piston Rod". (P.30 of IL.28-5) 

This PO was with the "Same" PDF file as the "Two letters (Attachment A and Attachment B)"). 

SOURCE: DOE - Office of Legacy Management -- Granite City IL Site - IL 28 "CLICK" 

See p. 30 

The "Two letters (Attachment A and Attachment B)" could be for "anything" done by GSI for Mallinckrodt. There is 

no mention in the "Two letters (Attachment A and Attachment B)" of Betatron work, X-rays, hours etc. 

Another "possible" reason for a "split/ partial" Purchase order or owed money, is that MCW Destrihan
 

Plant operation "moved" to Weldon Spring in 1958.
 

That may have caused some partial PO payments. (There are NO purchase orders prior to 1958.) 

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